- 8 - deficiency determinations resulted from petitioners’ alleged failure to report HRDC’s income from the extras and certain other sales, as well as petitioners’ unreported bank deposits. For 1994, respondent determined that petitioners received unreported income from HRDC of $222,735. Respondent also reduced petitioners’ reported 1994 rental income by $23,241. The parties have stipulated that petitioners received $64,000 in unreported income from HRDC in 1993, and petitioners conceded that in addition unreported taxable deposits of $3,681 were made into petitioners’ bank account in 1993. The parties have also stipulated that petitioners received $42,335 in unreported income from HRDC in 1995, and, in addition, unreported deposits of $30,953.94 were made into petitioners’ bank account in 1995. The parties dispute, inter alia, whether petitioners underreported their 1994 income and whether the unreported bank deposits in 1995 were taxable. OPINION I. Burden of Proof The parties do not address the burden of proof. Respondent’s revenue agent first met with petitioners in late 1997 after the start of his examination of their 1993, 1994, and 1995 returns. Because respondent’s examination of petitioners’ returns began before July 22, 1998, section 7491 does not apply. See Internal Revenue Service Restructuring and Reform Act ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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